Eversheds Sutherland Cybersecurity and Privacy Insights Blog
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SEC Moves to Update Transfer Agent Rules; New Rules Likely to Impact Unclaimed Property and Cybersecurity

On December 22, 2015, the Securities and Exchange Commission took the first step in overhauling SEC regulation of transfer agents, the little-discussed but critical intermediaries involved in the prompt clearance and settlement of almost all U.S. securities. After many years in which other types of financial market intermediaries took center stage on the SEC’s rulemaking agenda, the...

The SEC’s Cybersecurity Enforcement Action: Rulemaking by Enforcement

The Securities and Exchange Commission recently brought an enforcement action against an investment adviser that, like a large number of companies, was the victim of a cyberattack. Although the SEC did not allege that any of the firm’s clients suffered harm, the Commission nonetheless sanctioned the firm for its allegedly unreasonable policies and procedures. In their article for...

SEC Charges Investment Adviser with Failure to Adopt Required Cybersecurity Policies Prior to Breach

On September 22, the Securities and Exchange Commission (SEC) announced that it had entered into a settlement order with R.T. Jones Capital Equities Management, Inc., a St. Louis-based SEC registered investment adviser, for failure to establish required cybersecurity policies and procedures in advance of a breach. As a result of the firm’s failure to adopt reasonable cybersecurity...

They’re Baaaack . . . SECs Office of Compliance Inspections and Examinations Releases New Cybersecurity Risk Alert

Yesterday, the U.S. Securities and Exchange Commission (SEC) Office of Compliance Inspections and Examinations (OCIE) released a Risk Alert describing OCIE’s 2015 cybersecurity exam initiative.  [link to www.sec.gov/ocie/announcement/ocie-2015-cybersecurity-examination-initiative.pdf].  As the Risk Alert notes, OCIE’s new cybersecurity initiative builds on information OCIE learned from...